# Do NEMT Companies Need a USDOT Number? 2027 Rules for State Lines, Van Size, and Operating Authority

Canonical URL: https://nemtguide.com/guides/dot-number-for-nemt/ · Updated 2026-09-29

It depends on your trips and vehicles. A NEMT company paid for trips that cross a state line needs FMCSA operating authority and a USDOT number, even in a minivan, unless an exemption applies. Vans rated 10,001 pounds or more, or built for 9 or more people, add federal safety rules. In-state trips follow state law, and Minnesota requires a USDOT number from every special transportation provider.

- Two facts decide the federal answer: whether a paid trip crosses a state line, and what vehicle carries it.
- Paid trips across a state line need FMCSA operating authority even in a minivan, with $1.5 million in liability coverage on file.
- Vans built for 9 or more people and paid per ride, or rated 10,001 pounds or more, add driver, hours, and maintenance rules on interstate trips.
- A vehicle designed for 16 or more people needs a CDL driver even on trips that never leave your state.
- For in-state trips your state decides. Minnesota and Texas ask for USDOT numbers, and Pennsylvania wants its own PUC authority.

Most NEMT companies start with minivans and small wheelchair vans on trips inside one state. For them the federal answer is usually no. That changes the day a paid trip crosses a state line, or a van is big enough to count as a commercial motor vehicle. The rules below are federal unless a state is named, current as of September 2026.

## When federal rules reach a NEMT trip

Two questions decide it: where the trip goes, and what vehicle carries it.

### Does the trip cross a state line?

The Federal Motor Carrier Safety Administration (FMCSA) regulates interstate commerce ([49 CFR 390.5T](https://www.ecfr.gov/current/title-49/section-390.5T)). A trip is interstate when it:

- goes from your state to another state,
- runs between two places in your state but passes through another state on the way, or
- is the in-state part of a longer trip that starts or ends outside your state.

NEMT trips cross lines more often than new owners expect. Georgia's NEMT policy manual (version date July 1, 2026) makes its brokers responsible for rides to health care providers up to 50 miles beyond Georgia's borders. MTM Health's Virginia handbook (approved August 10, 2026) mentions vehicles garaged in neighboring states. FMCSA's guidance also says a ground ride booked ahead as part of an interstate flight can be interstate commerce even when the ride stays in one state. See out-of-state NEMT trips.

One trip is enough. FMCSA keeps jurisdiction over a carrier, its vehicles, and its drivers for 4 months after a trip in interstate commerce (Appendix A to 49 CFR part 390).

### Is the trip paid?

A carrier paid for the ride is for-hire. FMCSA's guidance says compensation is the main factor that makes a trip for-hire, and that it can take many forms. A trip paid by Medicaid, a broker, a health plan, a facility, or the rider is a paid trip.

For vans built for 9 to 15 people, the form of pay matters too. FMCSA defines direct compensation as payment to the carrier by the passengers, or a person acting for them, for the ride itself, and not bundled into a package charge. The section on 9 to 15 passenger vans below explains why that line matters.

### What vehicle carries it?

On interstate trips, a vehicle is a commercial motor vehicle when any of these is true (49 CFR 390.5T):

| Vehicle | Commercial motor vehicle on interstate trips? |
|---|---|
| Gross vehicle weight rating (GVWR) of 10,001 pounds or more | Yes, whatever the seating |
| Designed or used for 9 to 15 people, driver included | Yes, when paid |
| Designed or used for 16 or more people, driver included | Yes, paid or not |
| Sedan, minivan, or wheelchair van for 8 or fewer people, driver included, under 10,001 pounds | No |

The GVWR is printed on the certification label on the hinge pillar, door-latch post, or door edge next to the driver's seat ([49 CFR 567.4](https://www.ecfr.gov/current/title-49/section-567.4)). A company that converts a van for wheelchairs adds its own label, with the new rating if the conversion changed it ([49 CFR 567.7](https://www.ecfr.gov/current/title-49/section-567.7)). Read the labels on the van you own, not the brochure.

## USDOT number, operating authority, and the other filings

People say "DOT number" for several separate registrations. A NEMT company can need some without the others.

| Registration | What it is | Who needs it | Cost, as of September 2026 |
|---|---|---|---|
| USDOT number | FMCSA's identification number for your safety record | Carriers running commercial motor vehicles across state lines, for-hire passenger carriers with operating authority, and in-state carriers where the state requires one | No fee for the number itself |
| Operating authority (MC number) | Permission to carry paid passengers across state lines | For-hire interstate passenger carriers, whatever the vehicle size, unless an exemption applies | $300 for each type of authority ([49 CFR 360.3T](https://www.ecfr.gov/current/title-49/section-360.3T)) |
| Insurance filing | Proof of liability coverage filed with FMCSA on Form BMC-91 or BMC-91X, or a BMC-82 surety bond | Holders of passenger operating authority | Coverage of at least $1.5 million if every vehicle seats 15 or fewer, driver included, or $5 million with any 16 seat vehicle ([49 CFR 387.33T](https://www.ecfr.gov/current/title-49/section-387.33T)) |
| Process agent (Form BOC-3) | A named agent in each state you operate in or drive through, to accept legal papers for you | Holders of operating authority | Set by the agent company |
| Unified Carrier Registration (UCR) | A yearly registration and fee paid through your base state | Carriers running vehicles rated 10,001 pounds or more, or designed for more than 10 people, driver included, across state lines | $46 for 0 to 2 vehicles for 2026, and $55 for 2027 ([91 FR 56063](https://www.federalregister.gov/documents/2026/09/01/2026-17893/fees-for-the-unified-carrier-registration-plan-and-agreement), effective October 1, 2026) |
| Commercial driver's license (CDL) | A license class for the driver | Drivers of vehicles designed for 16 or more people, driver included, or rated 26,001 pounds or more, in or out of state | Set by your state |

Before a carrier of passengers begins interstate operations, it must register with FMCSA and receive a USDOT number, and for-hire carriers must also get operating authority unless their trips are exempt ([49 CFR 385.301T](https://www.ecfr.gov/current/title-49/section-385.301T)). In FMCSA's new registration system, first-time applicants apply for both in the same place.

Skipping it is expensive. Federal law sets a civil penalty of at least $25,000 for each violation when a carrier transports passengers without the registration it needs ([49 U.S.C. 14901](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title49-section14901&num=0&edition=prelim)).

FMCSA has proposed dropping MC numbers, so that the USDOT number becomes the only identifier. As of its April 16, 2026 update, FMCSA says the change is under consideration and not part of the first release of its new system.

## Which NEMT setups need what

| Your setup | USDOT number | Operating authority | Federal safety rules | CDL |
|---|---|---|---|---|
| Sedans, minivans, or wheelchair vans for 8 or fewer, under 10,001 pounds, trips stay in your state | Only if your state requires one | No | No | No |
| The same vehicles, with paid trips across a state line | Yes | Yes, with $1.5 million filed | No | No |
| A van designed for 9 to 15 people, under 10,001 pounds, paid per ride across a state line | Yes | Yes, with $1.5 million filed | Yes | No |
| Any vehicle rated 10,001 to 26,000 pounds, designed for 15 or fewer, paid trips across a state line | Yes | Yes, with $1.5 million filed | Yes | No |
| A bus designed for 16 or more people, trips stay in your state | Only if your state requires one | No | Drug and alcohol testing for CDL drivers, state rules for the rest | Yes |
| The same bus with trips across a state line | Yes | Yes, with $5 million filed | Yes | Yes |

The second row surprises owners most. FMCSA says for-hire carriers in interstate commerce must get operating authority "no matter how small or light the vehicle(s) used, unless exempted," while the safety rules reach only commercial motor vehicles (Appendix A to 49 CFR part 390). So a minivan company with regular out-of-state trips needs authority and a $1.5 million filing. That is three times the $500,000 combined single limit in MTM Health's standard agreement (the January 1, 2023 version Pennsylvania posts). See [NEMT insurance requirements](https://nemtguide.com/guides/nemt-insurance-requirements/).

Where the table says the safety rules apply, read the exception for sick and injured persons in the exemptions section below before you decide.

Brokers check. Virginia's fee-for-service NEMT rules (updated May 26, 2026) require providers that accept out-of-state trips to hold FMCSA operating authority. MTM Health's Virginia handbook asks for USDOT or FMCSA interstate authority when required, and the company profile it keeps on you records your FMCSA authority and its expiration date.

## Seat counts, converted vans, and the 9 to 15 passenger line

**Designed seating counts, not the seats you left in.** For the CDL test, FMCSA says "designed to transport" means the original design, and removing seats does not change it as long as the vehicle still carries passengers (CDL guidance on 49 CFR 383.5, issued March 1, 2019). A bus built for 16 that you converted to four wheelchair positions still needs a CDL driver.

**Vans for 9 to 15 people.** FMCSA's page on small passenger-carrying vehicles (updated July 31, 2019) splits them by how you are paid:

- **Direct compensation**, such as a fee for each ride. On interstate trips you follow parts 385 and 390 to 396: registration, new entrant procedures, an accident register, driver qualification and medical exams, driving time limits, duty status or time records, and inspection and maintenance records.
- **Indirect compensation**, where the ride is bundled into another charge, such as a day program fee. You still register, mark the vans, keep an accident register, and follow the texting and phone rules ([49 CFR 390.3T](https://www.ecfr.gov/current/title-49/section-390.3T)(f)(6)).

Plan on the first group for NEMT paid per trip, and confirm with FMCSA at 800-832-5660. If you run 12 or 15 passenger vans for a day program or a facility contract, ask how the contract pays before you decide which rules apply.

## How to register with FMCSA in Motus

FMCSA launched its new registration system, Motus, in May 2026, and it replaced the older systems for new applications. If your trips cross state lines, follow these steps before the first one.

1. **Confirm what you need.** FMCSA's USDOT wizard asks a few questions and says whether you need a USDOT number alone or operating authority too. For help, call FMCSA at 800-832-5660.
2. **Create a Motus user profile** at motus.dot.gov. It uses Login.gov and identity verification, and each profile belongs to one person.
3. **Create your company account and apply.** Use your legal name or one trade name, the same one on your other records ([49 CFR 390.19T](https://www.ecfr.gov/current/title-49/section-390.19T)). Apply for the USDOT number and passenger carrier authority, and pay $300 for each authority type. FMCSA's April 29, 2026 notice says for-hire passenger carriers are to register through Motus, and paper forms, where still accepted, take at least eight business days just for the first review.
4. **Have your insurer file, and file your process agent.** The insurer files Form BMC-91 or BMC-91X, and you file Form BOC-3. Both are due within 20 days after FMCSA publishes notice of your application in the FMCSA Register ([49 CFR 365.109T](https://www.ecfr.gov/current/title-49/section-365.109T)). FMCSA says that if the insurance filing is late, it serves a decision saying the application will be dismissed unless you comply within 60 days. Others have 10 days after publication to protest ([49 CFR 365.115](https://www.ecfr.gov/current/title-49/section-365.115)).
5. **Wait for the grant.** Run no interstate trips until your authority is active.
6. **Mark each commercial motor vehicle** with your legal or trade name and "USDOT" followed by your number, on both sides, in contrasting letters readable from 50 feet in daylight ([49 CFR 390.21T](https://www.ecfr.gov/current/title-49/section-390.21T)). See NEMT vehicle signage.
7. **Register for UCR** each year if you run vehicles that count under the UCR rules.
8. **File the biennial update** every 24 months. FMCSA charges nothing for it. The last digit of your USDOT number sets the month and the next-to-last digit sets odd or even years. A missed update can deactivate your number. As of September 10, 2026, FMCSA has temporarily stopped deactivating numbers for missed updates due on or after June 1, 2026, so file on time anyway.

If your vehicles are commercial motor vehicles, expect new entrant oversight too. FMCSA monitors a new entrant for 18 months ([49 CFR 385.307](https://www.ecfr.gov/current/title-49/section-385.307)), and for passenger carriers the safety audit is due within 120 days ([49 CFR 385.3](https://www.ecfr.gov/current/title-49/section-385.3)).

## What changes when your vans are commercial motor vehicles

Once a van meets the commercial motor vehicle test on paid interstate trips, these federal rules apply to it and its drivers:

| Rule | What it requires | Where |
|---|---|---|
| Driver qualification file | Application, driving records, road test, and medical certificate for each driver, kept for employment plus 3 years | 49 CFR 391.51 |
| Medical certificate | An exam and certificate at least every 24 months | 49 CFR 391.45 |
| Yearly driving record review | A motor vehicle record from each licensing state every 12 months, reviewed and noted | 49 CFR 391.25 |
| Hours of service | No more than 10 hours driving after 8 hours off, no driving after 15 hours on duty, and 60 hours in 7 days or 70 in 8 | 49 CFR 395.5 |
| Inspection and maintenance | Records of inspection, repair, and maintenance | 49 CFR part 396 |
| Accident register | A record of reportable crashes, kept 3 years | 49 CFR 390.15 |
| Marking | Name and USDOT number on both sides | 49 CFR 390.21T |

Drug and alcohol testing under part 382 applies only to drivers who need a CDL ([49 CFR 382.103](https://www.ecfr.gov/current/title-49/section-382.103)). Brokers often require testing anyway. MTM Health's standard agreement asks for pre-employment, post-accident, reasonable suspicion, and random tests.

Waiting at a clinic can count toward the 15 hours unless the driver is relieved from duty ([49 CFR 395.2](https://www.ecfr.gov/current/title-49/section-395.2)), so long dialysis waits matter. The [rural NEMT guide](https://nemtguide.com/guides/rural-nemt/) covers hours of service and the short-haul exception, and hours of service rules and the NEMT DOT physical explain each piece.

## The CDL line applies even inside your state

The CDL rules in part 383 apply in both interstate and intrastate commerce (49 CFR 390.3T(b)). A driver needs a CDL for a vehicle designed for 16 or more people, driver included, or one rated 26,001 pounds or more ([49 CFR 383.5](https://www.ecfr.gov/current/title-49/section-383.5)). FMCSA's examples add that a driver of a 16 passenger vehicle needs the passenger endorsement and must be in a part 382 drug and alcohol testing program.

A minivan, or a wheelchair van built for 15 or fewer and rated under 26,001 pounds, is below both lines. See [do NEMT drivers need a CDL](https://nemtguide.com/guides/do-nemt-drivers-need-a-cdl/).

## Trips that stay in one state: state rules decide

FMCSA lists 38 states and Puerto Rico that require some intrastate commercial vehicle registrants to get a USDOT number (updated September 3, 2025): Alabama, Alaska, Arizona, California, Colorado, Connecticut, Delaware, Florida, Georgia, Hawaii, Idaho, Indiana, Iowa, Kansas, Kentucky, Maine, Maryland, Massachusetts, Michigan, Minnesota, Missouri, Montana, Nebraska, Nevada, New Jersey, New York, North Carolina, Ohio, Oklahoma, Oregon, Pennsylvania, South Carolina, Texas, Utah, Washington, West Virginia, Wisconsin, and Wyoming.

Each state decides which vehicles count. A state on the list may not reach your minivan, and a state off it may still license you as a passenger carrier. Here is what six states ask of NEMT companies, as of September 2026:

| State | What it requires | Source |
|---|---|---|
| Minnesota | Every special transportation service provider applies for a USDOT number before MnDOT issues its STS number. The intrastate number has no fee. | MnDOT |
| Texas | A vehicle designed for more than 15 passengers, driver included, needs TxDMV motor carrier registration, and you need a USDOT number registered as intrastate first. A one-year certificate costs a $100 application fee, $10 per vehicle, and $100 for the insurance filing. | TxDMV |
| Indiana | For-profit common carriers need Indiana Motor Carrier Services certification, USDOT authority, or both, to enroll in Indiana Medicaid. | IHCP Provider Enrollment module, September 8, 2026 |
| Pennsylvania | Any paid trip that starts and ends in Pennsylvania needs PUC authority, and a federal USDOT number does not authorize in-state service. Most passenger applications cost $350 and take 3 months or longer. | PA PUC FAQ, June 25, 2024 |
| Virginia | NEMT providers that accept out-of-state trips must hold FMCSA operating authority, on top of state DMV authority. | DMAS, May 26, 2026 |
| Georgia | Carriers running certain vehicles only in Georgia register in the state's GIMC program. Carriers that cross state lines register under UCR instead. | Georgia DPS, 2026 registration year |

For every state's carrier license, see [NEMT license requirements](https://nemtguide.com/guides/nemt-license-requirements/), passenger carrier operating authority, and your [state guide](https://nemtguide.com/states/).

## Exemptions to ask FMCSA about first

Federal law carves out some trips, but each carve-out has conditions. Get FMCSA's answer in writing before you rely on one.

- **Taxicab service.** Taxicab service is exempt from operating authority: a vehicle for 8 or fewer people, driver included, not run on a regular route, that is licensed as a taxi or offers local rides priced mainly by distance ([49 U.S.C. 13506](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title49-section13506&num=0&edition=prelim)(a)(2) and 13102). The federal insurance rule excludes taxis seating fewer than 7 passengers that do not run a regular route ([49 CFR 387.27](https://www.ecfr.gov/current/title-49/section-387.27)). If you drive with taxi plates, MTM Health's Virginia handbook also requires you to follow local taxi rules.
- **Commercial zones.** Trips entirely within a city, neighboring cities, or the commercial zone around them are exempt from operating authority (49 U.S.C. 13506(b)(1)). On a route that crosses a state line, the exemption holds only if you lawfully provide intrastate passenger service over the entire route under each state's law. In one FMCSA example, an assisted living community's bus that took residents into a neighboring state, all within its commercial zone, needed no authority but still needed a USDOT number, the safety rules, and $5 million in coverage.
- **Airport rides.** Rides for passengers flying just before or after are exempt from operating authority when the ride stays within 25 miles of the airport boundary, or inside the commercial zone of a city that reaches into that radius (49 U.S.C. 13506(a)(8)(A) and [49 CFR 372.117](https://www.ecfr.gov/current/title-49/section-372.117)). FMCSA's guidance says that exemption does not reach the safety rules.
- **Sick and injured persons.** The federal safety rules do not apply to "the transportation of human corpses or sick and injured persons" (49 CFR 390.3T(f)(4)). The rule does not define the phrase or say whether it reaches NEMT, so ask FMCSA before you rely on it. It does not remove drug and alcohol testing for CDL drivers (49 CFR 382.103(c)). The operating authority requirement is in the statute ([49 U.S.C. 13901](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title49-section13901&num=0&edition=prelim)), and the statute's exemption list in 13506 has no medical exemption.
- **Vans for 9 to 15 people not paid directly.** These skip most safety rules but still register, mark vehicles, and keep an accident register (49 CFR 390.3T(f)(6)).

## A quick check before you take an out-of-state trip

1. Read the GVWR label, any converter's label, and the original seating capacity of each vehicle.
2. List every trip that crosses a state line, including rides to or from an airport for a flight.
3. If any paid trip crosses a line, get operating authority, a USDOT number, the $1.5 million filing, and a BOC-3 first.
4. If a vehicle is a commercial motor vehicle, set up driver files, medical cards, hours records, and maintenance records.
5. If a vehicle is designed for 16 or more people, hire CDL drivers with the passenger endorsement and enroll them in drug and alcohol testing.
6. Ask each broker which federal and state credentials it wants on file, and keep the [NEMT vehicle requirements](https://nemtguide.com/guides/nemt-vehicle-requirements/) checklist with your records.

## Frequently asked questions

### Do I need a USDOT number if my NEMT trips stay in one state?

Not under federal rules, unless you haul hazardous materials. Your state may still require one. Minnesota requires a USDOT number from every special transportation service provider, and Texas requires one for vehicles designed for more than 15 passengers, driver included. Pennsylvania instead requires its own PUC authority for any paid trip that starts and ends in the state, and says a USDOT number does not replace it.

### Do I need an MC number for NEMT?

Only for paid trips that cross a state line. FMCSA says for-hire carriers in interstate commerce need operating authority, the registration that comes with an MC number, no matter how small the vehicle, unless an exemption applies. It costs $300 for each type of authority. FMCSA has proposed dropping MC numbers so the USDOT number becomes the only identifier, but as of its April 16, 2026 update that change was still under consideration.

### How much does a USDOT number cost?

FMCSA charges nothing for the USDOT number itself. Interstate passenger carriers pay $300 for each type of operating authority. If you run vehicles across state lines that are rated 10,001 pounds or more, or designed for more than 10 people, you also pay a yearly Unified Carrier Registration fee: $46 for 0 to 2 vehicles in 2026, rising to $55 for 2027. The $1.5 million liability policy your insurer must file with FMCSA usually costs far more than the filings.

### Does a wheelchair van need a USDOT number?

Only if its trips reach federal or state rules. A wheelchair van built for 8 or fewer people, driver included, and rated under 10,001 pounds is not a commercial motor vehicle, but paid trips across a state line still need operating authority and a USDOT number. A larger van rated 10,001 pounds or more, or built for 9 or more people, also brings the federal safety rules on those trips. Check the weight rating on the label by the driver door.

### What insurance do I need for NEMT trips across state lines?

At least $1.5 million in public liability coverage if every vehicle seats 15 or fewer people, driver included, or $5 million if any vehicle seats 16 or more (49 CFR 387.33T). Your insurer files proof with FMCSA on Form BMC-91 or BMC-91X, or a surety files a BMC-82 bond. Brokers can ask for more. WellTrans in Indiana, for example, requires $1.5 million per accident for sedans, vans, and wheelchair vans.

### Do NEMT drivers need a DOT medical card?

Under federal rules, only drivers of commercial motor vehicles on interstate trips, such as a van built for 9 to 15 people on trips paid per ride, or any vehicle rated 10,001 pounds or more. Those drivers must be examined and certified at least every 24 months (49 CFR 391.45). Drivers of minivans and small wheelchair vans do not need one under federal rules, though a state or broker can require a physical.

### Does one trip across a state line really matter?

Yes. FMCSA keeps jurisdiction over a carrier, its vehicles, and its drivers for 4 months after a trip in interstate commerce, and records must be kept for as long as the rules require. A single paid out-of-state dialysis or specialist trip can bring operating authority and, for larger vans, the full safety rules. The civil penalty for carrying paid passengers without registration is at least $25,000 per violation, so hand those trips back until your authority is active.

## Official resources

- [FMCSA: Do I need a USDOT number?](https://www.fmcsa.dot.gov/registration/do-i-need-usdot-number)
- [FMCSA: Get operating authority (docket number)](https://www.fmcsa.dot.gov/registration/get-mc-number-authority-operate)
- [Motus: FMCSA USDOT registration system](https://motus.dot.gov/)
- [FMCSA: Small passenger-carrying vehicles](https://www.fmcsa.dot.gov/registration/small-passenger-carrying-vehicles)
- [FMCSA: Insurance filing requirements](https://www.fmcsa.dot.gov/registration/insurance-filing-requirements)
- [eCFR: Appendix A to 49 CFR part 390 (passenger carrier applicability, with examples)](https://www.ecfr.gov/current/title-49/subtitle-B/chapter-III/subchapter-B/part-390/appendix-Appendix%20A%20to%20Part%20390)
- [eCFR: 49 CFR 390.5T, Definitions](https://www.ecfr.gov/current/title-49/section-390.5T)
- [MnDOT: Become a special transportation service provider](https://www.dot.state.mn.us/cvo/sts/becomeaprovider.html)
- [TxDMV: TxDMV Number](https://www.txdmv.gov/motor-carriers/txdmv-number)